ML20212L241

Forwards QA Procedures,Including Rev 0 to Nqap 100, Nuclear QA Dept Organization... & Ndp 300-2, Selection of Procurement Sources & Addl Info,In Response to 861120 Request for Addl Justification Re Rev 11 to QA Program

ML20212L241
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	01/09/1987
From:	Lindblad W PORTLAND GENERAL ELECTRIC CO.
To:	Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20212L243	List: ML20212L241 ML20212L257 ML20212L271 ML20212L281 ML20212L294
References
NUDOCS 8701290383
Download: ML20212L241 (14)

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121 S. W. S Atw o n S TsceT WILLI AM J. LIN DBLAO Po RTLA N o. O R EGO N 07204 oso3)22e-ee75 llEGIONVI&E January 9, 1987 Trojan Nuclear Plant Docket 50-344 License NPF-1 Mr. D. F. Kirsch, Director Division of Reactor Safety and Projects U.S. Nuclear Regulatory Commission, Region V 1450 Maria Lane, Suite 210 Walnut Creek CA 94596-5368

Dear Mr. Kirsch:

Quality Assurance Program for Trojan Operations The following responses to your November 20, 1986 letter request for additional justification or clarifications of specific changes in Revision 11 to the Nuclear Quality Assurance (QA) Program are provided.

Chapter 1.0 Organization NRC Comments a.

The Nuclear QA Department responsibilities contained in Revision 10, Section 1.2.2.1.2, are not addressed in Revision 11.

b.

The responsibilities of the QA Engineering Branch Manager - Operations contained in Revision 10 Section 1.2.2.1.2.2 (a), (b), (c), (d), (e),

(f), (h), and (1), are not addressed in Revision 11.

c.

The responsibilities and qualifications required for the position of Plant QA Supervisor are not adorosced in Revision 11 for the replace-ment position of Manager, QA Operations Branch.

d.

The Plant QA staff responsibilities contained in Revision 10, Section 1.2.2.1.4.7.2, are not addressed in Revision 11.

c.

Revision 10, Section 1.2.2.1.2.4

" Qualification Requirements for Nuclear Quality Assurance Department Personnel", are not addressed in Revision 11.

These deletiens appear to represent a reduction in commitments to the QA Program previously accepted. Therefore, please provide justification for these changen in accordance with 10 CFR 50.54(a)(3)(1) prior to implementation.

hO'f-8701290383 870109 PDR ADOCK 05000344 f$

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PORTLAND OENERAL ELECTRIC COMPANY

y Nr. D. F. Kirsch January 9, 1987 Page 2 PGE Responses None of the QA Department organizational changes are considered by PCE to

-be reductions in commitments. Changes made in Chapter 1.0 - Organization -

reflect the combining of the responsibilities of the prior Trojan Plant QA Group (which reported to the Plant General Manager) and the prior Nuclear QA Department into one orgaulzation under the direction of the Nuclear QA Department Manager, s.

With the reorganization of the PCs Nuclear QA Department, the depart-ment responsibilities contained in Revision 10, Section 1.2.2.1.2 were assigned to specific branches or groups of the new Nuclear QA Depart-ment. The Nuclear QA Department' responsibilities previously contained in Revision 10, Section 1.2.2.1.2, are now collectively covered in Revision 11, Section 1.2.2.1.2, as primary responsibilities and in WQAP 100 Revision 0, " Nuclear Quality Assurance Department Organiza-tional Responsibilities" (attached to this letter) as detailed specific responsibilities.

b.

The responsibilities of the QA gngineering Branch Manager - Operations contained in Revision 10, Section 1.2.2.1.2.2 (a), (b), (c), (d), (e),

(f), (h), and (i), are now collectively addressed as the responsibil-itles of the Branch Manager, QA Operations in Revision 11 Sec-tion 1.2.2.1.2a, and NQAP 100, Revision 0, Attachment C Pages 5 and 6.

The responsibilities and qualifications required for the eliminated c.

position of Plant QA Supervisor are collectively addressed in Revi-sion 11 Section 1.2.2.1.2.a and NQAP 100, Revision 0, Attachment B, and Attachment C, Pages 5 and 6, as responsibilities and qualifications of the Branch Manager, QA Operations, and/or in Revision 11, Sec-tion 1.2.2.1.2.d and NQAP 100 Revision 0, Attachment B, and Attach-ment C, Pages 9 and 10, as responsibilities and qualifications of the Quality Control Supervisor.

d.

Those responsibilities previously defined as Plant QA Staff responsi-bilities in Revision 10, Section 1.2.2.1.4.7.2, are now collectively covered by the staffs of the Branch Manager, QA Operations, and of the Quality Control Supervisor. These responsibilities are collectively contained in Revision 11, Sections 1.2.2.1.2a and c; and in NQAP 100, Revision 0, Attachment C, Pages 5, 6, 9, and 10.

e.

The qualification requirements for Nuclear QA Department personnel previously addressed in Revision 10 Section 1.2.2.1.2.4, are now addressed in NQAP 100, Revision 0, Attachment B, and cover all positions created by the QA Department reorganization.

PCs remains committed to the qualification requirements for personnel given in NRC regulatory guidance contained in NRC Regulatory i

Guide 1.8, Revision IR, May 1977 as stated in the QA Manual Introduction, Page lx.

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PORTLAND GENERAL ELECTRIC COMRANY Mr. D. F. Kirsch January 9, 1987 Page 3 To resolve your concern that these deletions appear to represent a reduction in commitments, the attached interim change will be processed to replace Revision 11, Section 1.2.2.1.2.

Chapter 2.0. Quality Assurance Program NRC Comment Section 2.2.1, Revision 10. Page 2-2, third paragraph, regarding QA Program implementing procedures, was not addressed in Revision 11.

Please provide justification for this deletion in order for us to evaluate the acceptability of this change.

PCE Response Section 2.2.1, Revision 10 Page 2-2, third paragraph, was deleted as being partly obsolete and partly redundant. The first sentence referred to the " orderly transition from the construction phase to the operating phase" which occurred over 10 years ago.

The second sentence regarding use of implementing procedures is considered to be adequately covered in Section 2.2.2, Quality-Related Procedures, and Chapter 5.0, Instructions.

Procedures, and Drawings.

Chapter 7.0. Control of Purchased Material. Equipment, and Services NRC Comment Section 7.2 of Revision 10 required QA approval for an Evaluation Request and Report Form for a supplier not on the Evaluated Contractor and Supplier List. Revision 11 requires use of a similar form but without QA approval.

Please provide clarification for this omission.

PCE Response The Evaluation Request and Report Form (Form Q105A, Revision 7) referred to in Section 7.2 of Revision 10 of the PGE QA Program is now obsolete.

Form Q105A was a dual purpose form that included both the request for a contractor or supplier evaluation and provisions for documenting the i

results of the evaluation.

Five new Nuclear Division Procedures (NDPs) were developed in 1986 as part of the effort to improve PCE's Procurement QA practices. One of these NDPs (NDP 300-2) contains two forms (Attachments A and B) that serve both as replacements and enhancements to the evaluation request and i

I documentation of evaluation results previously accomplished on Form Q105A.

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PORTLAN D GEN ER AL ELECTRIC COM PANY Mr. D. F. Kirsch January 9, 1937 Pago 4 Chapter 10.0 Inspection NRC Comments a.

Section 10.2.a required inspection procedures to contain, as a minimum, identification of characteristics to be inspected, including mandatory hold points. Please providn justification for deletion of the requirement for mandatory hold points from Revision 11.

b.

Sections 10.3.3.2 and 10.4.2.2 (Nonconformance). novision 10 contained the following requirement:

"If an inspoetion of a quality-related item or activity reveals that a nonconformance has occurred, the inspector has the authority and responsibility to suspend further activity, except for reactor startup and/or power generation, until the nonconformance is resolved." Please provide justification for this dolotion.

PCE Responses a.

Please note that Section 10.2, second paragraph of Revision 11, states in part that:

" Inspection plans or procedures provido for the use of the necessary drawings and specifications. Where necessary, they provido for establishing mandatory hold points for witness by inspection."

The use of mandatory hold points has not been deleted from Revi-sion 11 and they are still to bo included in appropriate documents.

However, it is not necessary that hold points always be contained within the inspection proceduro. This is consistent with 10 CFR 50, Appendix B, Critorion X.

b.

The changes made to Sections 10.3.3.2 and 10.4.2.2 of Revision 10 were mado as a matter of clarification due to substantial changes made to PCE's correctivo action programs for control of nonconforming material, parts, or components (NDP 600-1, Revision 2) and for con-trol of nonconforming activities (NDP 600-2, Revision 2) (both attached to this letter). When an inspection reveals that a nonconformanco exists, correctivo action is initiated via NDP 600-1 or NDP 600-2 as appropriate.

Please note that Section 16.2.1, Paragraph 4 of Revision 11. still states that:

"The QA Department may initiato suspension of any operation except reactor startup or power generation when a condition considered advorce to quality has occurred or is developing."

PORTLAND OEN ERAL ELECTRIC COM PANY Mr. D. F. Kirsch January 9, 1987 Page 5 Chapter 15.0, Nonconformina Material. Parts, or Components and Corrective Action NRC Comment Section 15.2.3.

Please provide justification for not requiring an NCR to be generated when items are received without proper documentation.

PCE Response Please refer to attached Procedure NDP 600-1, Revision 2 Sections 5.1A, B, and C.

QC hold tags are used on items received without proper documentation.

Sincerely, fr Attachments 1.

Interim change.

2.

NQAP 100, Revision O.

3.

NDP 300-2, Revision O.

4.

NDP 600-1, Revision 2.

5.

NDP 600-2, Revision 2.

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Mr. David Kish, Acting Director State of Oregon Department of Energy Mr. Gary Kellund Resident Inspector Trojan Nuclear Plant

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is the principal correspondent with the NRC on matters pertaining the rojan Nuclear Plant and coordinates the interface between the ojan Nuclea Plant and offsite support organizations for resolution o :NRC l

comme 1ts d general correspondence. He has authority to pro de overall I

direction of he Trojan Nuclear Plant operations and to ap we initial procurement doc nts pertaining to the plant. He has legated to the plant General Mana r responsibility for operation o the Trojan Nuclear Plant and implementat n of this QA Program onsit.

1. 2. 2.1.1 Troian Nuclear rations Board The Trojan Nuclear Operations Boa orts to the Vice President.

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Nuclear, and performs offsite revi unctions required by the operating license. The TN08 annually eval tes t overall adequacy and effective-ness of the QA Program for th Trojan Nuc r Plant and semiannually reviews the QA audit progr to assure that a its are being accomplished in accordance with the quirements of the Techn al Specifications and 10 the QA Program. Add ionally, the TN08 is respons le for conducting an

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annual audit of t Nuclear QA Department. These rev and audits, j

themselves, ar periodicslly reviewed for effectiveness b the Vice l

President, clear.

The ership of the TN08 is prescribed in the Trojan Nuclear Pl t 10l Lic se, and NDP 500-1 provides a detailed description of the TN08 a

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s function.

1. 2. 2.1. 2 Nuclear Quality Assurance Denartment l

The Nuclear Quality Assurance Dehartment (hereaf ter referred to as the QA Department) is under the direction of the QA Manager. The QA Department is independent of the Trojan Nuclear Plant and other departments performing l

quality-related activities. The QA separtment has responsibility for the QA Program; for audits that are carried out to verify compliance with the 10 QA Program; and for evaluating the effectiveness of the QA Program for I

each area that is audited.

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The QA Department is staf fed with personnel who have the design, construc-tion, and operational quality assurance experience required by the QA Program.

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The QA Department has the fol'[owing responsibilities:

I Maintains the QA Prograsp the Nuclear Quality Assurance a.

Department Pro.;edtires (NQAPs);== & th blity fontrol Procedum(QCP5);

i b.

Evaluates and approves contractors', suppliers' and ser-vice c:1anizations' QA programs; 1

l c.

Provides for surveillance and inspection of quality-l related work perforined offsite by contractors, suppliers, and service organizations; i

i d.

Conducts surveillances and audits of the Trojan Nuclear i

Plant quality-related activities as specified in Chap-ter 18.0, Audits; i

i e.

Overview responsibility for the QA Program implementation; l

f.

Reviews for adequacy and approves the inclusion of appli-cable quality assurance requirements in specifications, l

offsite-originated purchase requisitions, and other docu-ments used in the procurement activity as they pertain to quality-related items; l

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g.

Reviews and concurs with all PGE support organizations' l

procedures relating to quality activities and all plant Quality Assurance Procedures (QAPs) as required by 10l NDP 100-g; i

h.

Selectively reviews design changes and modification docu-a l

ments for adequacy of quality requirements; i

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Initiates, recosumends, or provides solutions to identified quality-related problems through designated channels.

10l To control deviations from QA Program requirements, the QA Department has the authority and responsibility to initiate Stop Work Orders as necessary j

for any condition adverse to quality that has occurred or is developing.

i Conditions adverse to quality which appear to warrant "Stop Work" are isusediately reported through the QA Manager to the responsible management for corrective action. Conditions adverse to quality which appear to warrant suspending reactor startup or power generation are 1sumediately l

reported to the plant General Manager, or his designee, and the Vice Presi-l 10l dent, Nuclear, for their action. Suspension of reactor startup or power l

generation is at the direction of the plant General Manager or his designee.

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Conditions adverse to quality, noted during QA Department audits and sur-l Y

veillances, which directly affect plant activities, are reported to the l

plant General Manager for his action. Those which do not directly affect j

plant activities are reported to appropriate management of the activity audited for their action.

I The QA Department performs selected audits, surveillances, and reviews to

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verify that quality-related items are designed, specified, fabricated, I

shipped, stored, installed, inspected, and tested, and services related thereto are in accordance with applicable codes, specifications, and proce-

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dures. QA Department personnel are authorized access to Company records and personnel in the conduct of this responsibility.

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I Disputes, involving quality-related activities occurring due to a differ-w

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ence of opinion between the QA Vepartment and other departments or branches and which remain unresolved may be brought to the attention of higher I

management for resolution.

l Within the QA Department, two Quality Assurance Engineering eranch Managers j

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function to supervise and direct the activities of Quality Assurance Engi-l neers (QAEs) and implement the QA Department responsibilities.

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The QA Manager reports directly to the Vice President, Nuclear, and is responsible for preparing the initial QA Program and subsequent revi-i sions and recommending approval to the Vice President, Nuclear. The QA Manager has the authority and independence to identify quality problems; initiate, recommend or provide solutions to quality problems throtgh i

designated channels; and verify implementation of solutions to quality problems. The QA Manager manages the QA Eng4eeee6ag operations end-8"a*4,

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• Wee 4eer Support Branchet in the implementation of the overall QA Program, t

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The Quality Assurance' t; t;;r?ng Branch Manager 0;;retkm; (Wii; 4 has responsibilities which include the following:

a.

Acts for the QA Manager in his absence on quality assurance matters concerning Trojan Nuclear Plant operations; L

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i b.

Coordinates and schedules the activities of QAEs^and consultants conducting audits, surveillances, or reviews of the Trojan Nuclear Plant operations; onsite support organizations; and contractors, suppliers, and service organizations; c.

Reviews and approves audit, surveillance, and review reports of Trojan Nuclear Plant activities performed by the Operations 10 Branch, including audit findings and stop Work orders prior to 15

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Provides QA engineering support to the Trojan Nuclear Plant, other departments, and contractors by conducting QA orienta-tions; by reviewing design changes and modifications, specifica-tions and purchase requisitions; and by advising on quality methods, procedures, and techniques; Il 1-6 Revision M

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d %ffrN Interfaces with the Quality Assurance'! ;t'Gu. '.r-Branch e.

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A w Manager 0;;h;r I:: : ^. '"J ^^^ ^J,b to provide uniforin implementation of the QA Program and coordination of surveillances, audits, and support fi,nctions; Provides technical guidance to the plant Quality Assurance r

Supervisor (QAS) on plant procedures and practices regarding quality assurance including inspections, reviews, nonconfor-mances, and corrective actions when requested. Confers with the plant QAS on technical issues, audits, reviews, inspec-tions, nonconformances, corrective actions, and external relations with onsite contractors, suppliers, and service anizations.

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->-4 the PGE QA Program and QA Department procedures; h.

Verifies that quality assurance activities at the plant are performed in compliance with the QA Program through surveil-lances, audits, and reviews of plant QA audit and surveil-lance activities; 4

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Interfaces with the NRC Regional Office plant operations inspectors during *H+440-visits; co;4c

j. Reviews plant QAPs and recommends concurrence to QA Manager.

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has responsibilities under this Program which include the following:

a.

Acts for the QA Manager in his absence on quality assurance matters involving offsite activities;

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b.

Coordinates and schedules the activities of QAEs and il 1-7 Revision W

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i consultants conducting audits, surveillances, or reviews of offsite support organizations; c.

Reviews QA programs and procedures of offsite contractors, suppliers, and service organizations required to support the

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Trojan Nuclear Plant; 10l d.

Evaluates the quality and technical qualification of con-1 tractors, suppliers, and service organizations; reviews and approves offsite-prepared quality-related purchase requist-tiens; maintains and controls the Evaluated Contractor and 10 i

supplier List for Quality-Related Procurements;

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e.

Reviews and concurs in offsite PGE departmental QA procedures

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and coordinates interfacing procedures between departments; f.

Reviews and approves audit, surveillance, and review reports of offsite support organizations performed by the "rk:r Eapneee i

n ad Support Branch, including audit findings and stop Work Orders prior to issuoj,inu.s ani +'

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Assists in the development and maintenance of PGE QA Programs, QA Department Procedures, and Licensing Documents; Q A 06bi

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Interfaces with the QAEGM4 to provide uniform implementation of the QA Program and coordination of surveillances and audits of support organizations.

1.

Provides QA engineering support to offsite support departments i

and contractors b rforming activities for the Trojan Nuclear Plant by conducting QA orientations; by reviewing significant design changes and modifications, procedures, and specifica-tions, and by advising on quality methods, procedures, and techniques.

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l. 2. 2 I. ). 7 1.2.2.1.2.4 Oualification Reauirements for Nuclear Quality Assurance Senartment Personnel The QA Department Management and Staff must be knowledgeable of the QA Program and 10 CfR 50, Appendix B and maintain up-to-date knowledge of applicable regulatory guides, codes, and standards related to quality assurance.

QA Department Management personnel must meet all of the following qualifications:

a.

Graduate of a 4-year accredited engineering or science college or university; b.

Eight years experience in power plant engineering, con-struction, or operations; 4 years of this experience in the field of quality assurance, or equivalent number of

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years of nuclear plant experience in a supervisory g,osition, or a combination of the two; at least 1 year of this 4 years' experience shall be nuclear power plant experience in the implementation of the quality assurance program.

QA Department Staff QA Engineers must meet or exceed the following qualifi-cation requirements:

a.

Graduate of a 4-year accredited engineering or science college or university with 4 years' experience in power plant engineering, construction, or operations; 2 years of this experience in quality assurance or quality con-trol; 1 year of this experience in nuclear power plant quality' assurance program implementation; or b.

High school graduate with 8 years of exparience in quality assurance, engineering, manufacturing, con-(

struction, or plant operations and professional 11 j

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a engineering status; 2 years of this experience in quality assurance or quality control; 1 year of this experience in nuclear pet.or plant quality assurance i

program implementation.

\\ 2. 2.1.1 faeneral Manaaer. Technical Functions The eral Manager Technical Functions, reports to the Vice President Nuclear, and has been delegated responsibility for the direction and coordinat n of all engineering, safety and regulation, and other ch-10l nical effo necessary to support the Trojan Nuclear Plant. T General Manager, Techn cal Functions, directs the activities of the N lear Plant Engineering Depa nt, the Nuclear Safety & Regulation De rtment, and the Trojan Program roup.

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1. 2. 2.1. 3.1 Manaaer.

lear Plant Encineerina Den rtment The Manager, Nuclear Plant gineering, has pr ry responsibility for l

design control of the Trojan clear Plant ring operation to ensure safety, reliability, and effici cy of f lity operation. Under the direction of the Manager, Nuclear Ian Engineering, specifications are j

prepared, purchase requisitions are itiated, proposals are evaluated, design reviews of plant Requests r0 ign Change (ROCS) are conducted, and drawings and design docume s are pr ared. He performs or requests assistance from other organi tions in per raing safety evaluations of i

plant modifications or de gn changes to assu these changes do not o

involve any unreviewed fety questions, do not nvolve Technical Spect-l fication changes, do ot involve the Environmenta Impact Statement pre-viously prepared, do not degrade the fire protee on, radioactive Weste managemen, or security capabilities of the plan. He is responsible f the preparation, maintenance, and manag nt of the Inservice spection (151) Program for the Trojan Nuclear ant, and l

coordinates the activities of the contractors, plant, and et r support perso el in the conduct of the 151 Program. He is responsible for 10 management of the Welding Program which includes preparation and inte-n nce of the Welding Program procedures and welder qualifications f the st 1 10 Revision N

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